Privacy and Compliance Policy

This policy explains how The GTM Code Inc. ("GTM Code," "we" or "us") sources and licenses high-intent contact data, how you may use it, and how we handle the personal information you share with us. It works alongside your license agreement with us. If the two ever differ, the license agreement applies.

1. Where the data comes from

We license our data from an established third-party data provider. That provider has told us the data was collected in line with applicable data-sourcing laws. We don't collect consumer data ourselves.

We have the legal right to license the data to you for the purposes set out in your license agreement. Apart from that, the data is provided "as is." We don't guarantee that it is accurate, complete, up to date, deliverable or free of suppression-list flags.

2. What you're licensing

You receive a limited, non-exclusive, non-transferable license that we can revoke. You may use the data only for lawful sales, marketing and telemarketing aimed at people in the United States. The data is licensed to you.

Having someone's name, email address or phone number does not mean you have their permission to contact them, and it does not make contacting them legal.

3. Your responsibility for outreach

You are responsible for making sure your outreach is legal, and for getting any consent or registration the law requires. That includes the Telephone Consumer Protection Act (TCPA), the FTC Telemarketing Sales Rule, the CAN-SPAM Act, the National and state Do Not Call registries, U.S. state privacy and telemarketing laws and, where it applies, Canada's Anti-Spam Legislation (CASL).

• Calls, texts and autodialed outreach require prior express written consent and must follow the TCPA and the Telemarketing Sales Rule.
• Email must follow the CAN-SPAM Act.
• Social and professional platforms, like LinkedIn, have their own terms of service, which apply on top of the law.
• We supply the intent signal. How you contact people, and making sure each message is allowed, is your responsibility.

4. Ad platforms and the website pixel

Under your license agreement, you may upload the data to ad platforms to build custom, lookalike or seed audiences, and you may use our pixel to measure and identify visitors to your own website. Before you do, please understand:

• Ad platforms usually require consent. Platforms like Meta and Google generally expect the advertiser to have the person's consent and a direct relationship with them. Purchased data may not meet that requirement.
• Uploads are your decision and your risk. This includes lookalike and seed audiences. You're responsible for any result, such as a rejected audience or a restricted or suspended ad account.
• The pixel needs your own notices. Installing the pixel doesn't, on its own, make it legal to identify and retarget visitors. You need the notice-at-collection and opt-out options that state privacy laws require for cross-context behavioral advertising, including the California Consumer Privacy Act (CCPA), as amended by the CPRA.
• No platform guarantee. We don't promise that any upload or activity on an ad platform complies with that platform's terms.

5. Uses we don't allow

You may not use the data:

• For employment, credit, insurance, housing or other consumer-reporting decisions
• For political campaigns or political fundraising
• For government surveillance or profiling
• For unlawful discrimination, stalking or harassment
• For fraud or any unlawful purpose
• To train, fine-tune, test or benchmark AI or machine-learning models
• To reverse engineer how the data is sourced, scored or put together
• To build a competing data product or audience-intelligence service

6. U.S. data and where you can use it

The data covers people and businesses located in the United States. That doesn't limit where your company is based. You can operate from anywhere in the world.

However, you may use the data only for campaigns, ad audiences and pixel activity aimed at people in the United States. Using it to reach people outside the U.S. is not covered by your license. If you choose to do so, you're responsible for following the privacy, telemarketing, anti-spam and data-protection laws of those countries.

7. Your personal information

When you browse, order, pay or manage your account, we collect business information such as your contact details, transaction records and license-acceptance records. We handle it according to our Privacy Notice and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

We use this information only to fulfil orders, manage your license, keep the records our agreements and the law require, and communicate with you. We don't sell it. We share it only with service providers who help us run our business, or when the law requires it.

8. How this policy applies

This policy is part of your license agreement and stays in effect under its terms. Section headings are for convenience only.